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Circular File: Field of Screams

You probably remember the movie “Field of Dreams.” It starred Kevin Costner as a farmer who believed that if he built a baseball stadium in the back forty, people would come to watch games. No market studies or economic analysis were needed. Just a cornfield and a dream.

Disposal bans follow a similar logic. Banning a material from disposal — be it grass clippings, a computer or plastic bottles — will cause a recycling system to immediately spring into place for those products. The banned material is now guaranteed a useful afterlife.

Of course, these bans are just an extreme form of the strategy employed by most state recycling laws. Those laws do a good job of creating supplies of materials but usually fail to create corresponding markets for them. However, disposal bans differ in that they have the ability to do far more harm than good. As a recent report by the Congressional Research Service (CRS), “Managing Electronics Waste: Issues with Exporting E-Waste,” shows, serious problems are created when well-intentioned people act without considering the consequences.

The report analyzed the results of electronic product disposal bans that began earlier this decade in Massachusetts and California. Regulators and environmentalists in those states argued, without evidence, that the ban was necessary to protect the environment. Massachusetts tried to do the right thing through grants to e-waste recycling programs. In California, the state simply assumed that recycling would happen. Alas, e-cycling had no Kevin Costner.

As the CRS noted, due to a limited recycling infrastructure in this county and high demand in other countries, our banned e-waste was sent overseas. To make matters worse, they often went to facilities in countries with “few if any protections for workers or the environment.” Recycling operations in Guiyu, China, for instance, became notorious for their horrendous worker safety, environmental and health impacts.

What happened was that the unsubstantiated fears of environmental harm in this country lead to real environmental harm elsewhere. Or, as the CRS put it, “an unintended consequence of avoiding potential negative impacts of domestic e-waste disposal has been a contribution to actual environmental contamination and human health impacts to some communities in developing countries” (the italics are in the original report).

As the CRS noted, EPA says that electronics products can be safely disposed of in municipal solid waste landfills. EPA also supports reuse or recycling as the preferred waste management options. This makes sense. Electronics products have valuable components, such as gold and other metals, which can be recovered in an environmentally responsible way. But shouldn't we have taken the precaution to develop those processes and markets before we created a mess? Why ban without a plan?

Fortunately, EPA worked with a diverse group of e-waste recyclers, reclaimers and advocates to develop “Responsible Recycling Practices for Use in Accredited Certification Programs” (also known as “R2”). These guidelines can be used to assess electronics recyclers' environmental, worker health and safety, and security practices. They are a major step forward to cleaning up the mess created by the disposal bans.

I hope we have learned from our mistakes. When disposal bans are proposed in the future, their advocates have the responsibility to ensure that markets exist and the materials can be safely recycled. Let's not make the solution part of the problem.